Control Power

The President shall have control of all the executive departments, bureaus and offices. He shall ensure that the laws be faithfully executed.

Control the power of an officer to alter or modify or nullify orset aside what a subordinate officer had done in the performance of his duties and to substitute the judgment of the former for that of the latter.

Drilon v Lim (Control vs Supervision)

An officer in control lays down the rules in the doing of an act Supervision does not cover such authority. The supervisor or superintendent merly sees to it that the rules are followed, but he himself does not lay down such rules, nor does he have the discretion to modify or replace them.

Doctrine of Qualified Political Agency all the different executive and administrative organizations are alter egos of the Executive Department.

President has full control of all Cabinet members. He may appoint them, shuffle them, replace them without any legal inhibition since they are merely his alter ego

Not applicable to acts of cabinet secretaries done in their capacity ex officio

Villena v Sec. of Interior (Doctrine of Qualified Political Agency)

Without minimizing the importance of heads of various departments, their personality is a project of the President. Their acts performed and promulgated are, unless disapproved by President, presumptively the acts of the President.

Manubay v Garilao

A further appeal froma decision of a cabinet secretary may be taken to the Office of the President before resorting to judicial action, to be consistent with the Doctrine of Exhaustion of Administrative Remedies. (but this doctrine is not necessary/required if there is a special law that provides for a different mode of appeal)

Trade & Investment Development Corp v Manalang-Demigillo

Petitioner sought to justify its reorganization, as directed by its board of directors, by invoking this doctrine, stating that since the members of its board are cabinet secretaries, their act of providing for the reorganization should be considered as act of President.

HELD: Although SC upheld the validity of the reorganization, it did so based on other groumds, and not the doctrine of qualified political agency. Under Sec 10 of PD 8494, gi list ang mga ex officio members Evidently, it was the law, not the President, that sat them in the Board. Therefore, ex officio

Angeles v Gaite

SC upheld validity of memorandum circular issued by President, limiting his review of resolutions, orders or adjudications of the Secretary of Justice to offenses punishable by reclusion perpetua to death on the basis of the doctrine of qualified political agency. Plus, President has not totally abdicated his power of control as Memo Circular 58 allowas an appeal if the imposable penalty is reclusion perpetua or higher. // It would be unreasonable to impose upon the President the task of reviewing all preliminary investigations decide by SoJ. To do so will unduly hamper his othe important duties.